MFA Recommends Financial Market Reforms

In a letter to the SEC, the Managed Funds Association ("MFA") urged Acting Chair Mark T. Uyeda "to immediately halt, review, and provide relief from [specific] policies ... to reduce costs and burdens on market participants and improve the efficiency of the financial markets." 

The MFA recommended:

1. streamlining Form PF to make it consistent with its intended purpose—monitoring systemic risk.
2. enhancing investment opportunities by "streamlin[ing] the process for the development of investment products that invest in private markets under the Investment Company Act framework."
3. withdrawing the 2023 custody proposal "taking into consideration how markets have evolved."  
4. clarifying the scope of the Marketing Rule as it relates to institutional investors in private funds or separately managed accounts.  
5. revisiting the appropriateness of penalties under the Political Contributions of Advisers Rule.
6. reducing the complexity of Regulation SHO.
7. providing "common sense relief or guidance" on enforcement of Regulation M Section 105 ("Short selling in connection with a public offering") to support capital raising.
8. improving Treasury market infrastructure in support of central clearing.
9. rescinding new Schedule 13G ("Beneficial Ownership Reports") filing requirements on a quarterly basis or modify it to eliminate duplicative filings (by allowing filers to rely on Form 13F).
10. providing greater legal certainty for the regulation of digital asset securities.